PRIVACY AND PERSONAL DATA PROTECTION POLICY OF “PRIMEA PROPERTIES” LTD.

Information on the Processing and Protection of Personal Data

“PRIMEA PROPERTIES” LTD. is a company registered in the Commercial Register maintained by the Registry Agency under UIC: 147151793, with registered office and management address: 5 Baba Ganka Square, Burgas, Bulgaria, and operates the agency's website. The company processes your personal data in its capacity as a personal data controller within the meaning of the Bulgarian Personal Data Protection Act and the General Data Protection Regulation (GDPR).

This information outlines the approach to the lawful processing and protection of your data within the scope of the activities carried out by “PRIMEA PROPERTIES” LTD. It includes the following:

  1. What data we process

  2. Sources of data

  3. Purposes for which we process your data

  4. Direct marketing

  5. Legal grounds on which we process your data

  6. Third parties to whom we provide personal data

  7. Your rights as a data subject

  8. Data retention period

  9. Changes to this information

“PRIMEA PROPERTIES” LTD. considers the protection of the personal data of individuals whose data it processes to be a fundamental priority.

1. What Data We Process

In the course of its activities, “PRIMEA PROPERTIES” LTD. processes various types of personal data, which are grouped into the categories listed below.

Depending on the specific products and/or services you use, the agency may process some or all of the following data:

  • Personal information – names, personal identification number/date and place of birth, personal number of a foreign national, nationality, address(es), including country, identification document details, telephone number, email address, customer number, information about legal representatives and representatives acting under a power of attorney, owners/beneficial owners of capital, jurisdiction in which the individual is tax resident, details of persons through whom contact with a particular individual or legal entity is maintained, and other information.

  • Economic information – financial status and property rights, relationships between individuals.

  • Information collected when you use information and communication technologies, including:

    • IP addresses, online identifiers, username, password and log data;

    • Location information, e.g. from your mobile phone or IP address;

    • Information about the specific device, such as hardware model, operating system version, unique device identifiers and mobile network information, including telephone number;

    • Cookies that can uniquely identify your browser.

  • Information regarding products and/or services used – the services you have used and/or currently use and your specific requirements regarding them.

  • Communication information – information we learn about you from our correspondence with you.

In many cases, we also collect and process your data when you are not our client.

For example:

  • When you act as a representative, either by law or under a power of attorney, of one of our clients.

  • When you directly or indirectly participate in the ownership of a legal entity that is or wishes to become our client, we are required to identify its beneficial owner in fulfilment of our obligations under the Measures Against Money Laundering Act.

  • When you or a person you represent is a member of the governing bodies of a legal entity that is or wishes to become our client and the decisions of that body concern its relationship with us.

  • When you are designated as a contact person by our client or by a person with whom we have a contractual relationship.

  • When your data is provided to us in an inquiry or instruction concerning you or a person you represent, submitted by a state authority/institution or a person exercising public functions.

In all cases where we have access to and process your data, we undertake to comply with the principles set out in this document and with the applicable legislation on personal data protection.

2. Sources of Data

We collect the above-mentioned data through the following sources:

  • Information that you provide to us.

  • Information provided to us by third parties, such as state authorities/institutions, financial institutions, our partners, persons associated with you or your business, and persons exercising public functions.

  • Information we receive when you, or a person you represent, uses our services.

  • Information available in public registers, including the Property Register, BULSTAT Register and Commercial Register.

  • Cookies and similar technologies.

  • The Internet.

  • Video and audio surveillance and recording at the agency's office.

  • Other sources.

Before providing us with data belonging to a third party, you must ensure that you have informed that person and obtained their consent or have another lawful basis for doing so. You must also make them aware of this information concerning the processing and protection of their data within our organization.

If it is established, with or without the assistance of the competent authorities, that data concerning a third party has been provided without a lawful basis or without the consent and/or knowledge of the data subject, or in any other unlawful manner, “PRIMEA PROPERTIES” LTD. will delete the personal data and will make the necessary efforts to notify the data subject immediately, insofar as this is possible.

3. Purposes for Which “PRIMEA PROPERTIES” LTD. Processes Your Data

“PRIMEA PROPERTIES” LTD. processes your personal data for the following purposes:

  • Identification of clients and persons with whom the agency enters into relationships. Providing personal data is voluntary or is carried out in compliance with a legal requirement. If you refuse to provide the required data, “PRIMEA PROPERTIES” LTD. will not be able to provide the requested services.

  • Performance of agreements concluded between the agency and you/the person you represent.

  • Conducting marketing research, including obtaining information about brand perception, behaviour, needs and expectations of current and potential clients, with a view to developing/improving products and/or services and improving the level of customer service provided by the agency.

  • Storage and archiving of documents.

  • Protection of your vital interests or those of another individual.

  • Protection of the agency's legitimate interests, including in cases involving suspicions of abuse and/or fraud, money laundering, terrorist financing related to the relationship between you/the person you represent and the agency, as well as in potential legal disputes related to such relationships.

  • Reviewing and responding to inquiries, recommendations, complaints or claims submitted by you/the person you represent.

  • Sending you/the person you represent information, in paper or electronic form, regarding products and/or services you use.

  • Ensuring regulatory compliance of the agency's activities in accordance with applicable legal provisions and the general regulatory framework, including measures to prevent the use of the financial system for money laundering purposes and measures against terrorist financing.

  • Establishing, exercising or defending the agency's legal claims.

4. Direct Marketing

For the purposes of direct marketing, we use and process your data to inform you about our latest products and services and to offer you:

  • Better terms for products and/or services you already use.

  • Products that you do not currently use but which we believe may be of interest to you or your business.

  • Special offers prepared specifically for you or your business.

  • Products and services offered by our partners that “PRIMEA PROPERTIES” LTD. distributes in its capacity as an intermediary.

The information we hold about you consists of data that you have provided to us when using our products and services, information we collect when you use information and communication technologies, such as when visiting the agency's website to access our products, services and communication channels, as well as contact details that you have published on publicly accessible websites, such as websites maintained by you or persons you represent, contact information published in the Commercial Register and the Register of Non-Profit Legal Entities, and others.

We process this information so that we can assess your potential needs and interests regarding the products and services offered by the agency. The assessment based on the available data is compared with the terms of our products/services and those of our partners. In this way, we seek to determine which products, services and related offers may be interesting and useful to you as an existing or potential client with whom we wish to continue or establish a mutually beneficial relationship.

If you do not wish to receive marketing communications, you have the right to object to the processing of your personal data for direct marketing purposes in one of the following ways:

  • By submitting a written declaration at the agency's office.

Upon receiving your objection, the agency will cease processing your data for these purposes.

5. Legal Grounds on Which “PRIMEA PROPERTIES” LTD. Processes Your Personal Data

“PRIMEA PROPERTIES” LTD. processes your personal data lawfully on the legal grounds provided for under Article 6 of the General Data Protection Regulation.

Contractual Basis

We process your personal data when this is necessary to take steps at your request prior to entering into a contract with you/the person you represent, or for the performance of a contract already concluded with the agency.

Legal Obligation

Where “PRIMEA PROPERTIES” LTD. is subject to various legal obligations under national and EU legislation, the agency processes your personal data in order to comply with the relevant obligations applicable to it.

For example, we process personal data in order to fulfil our obligations concerning the prevention of money laundering and terrorist financing, as well as for the submission of information and reports to state authorities in accordance with the Tax and Social Security Procedure Code and other applicable legislation.

Legitimate Interest

In a number of cases, the agency processes your data on the basis of its legitimate interests, for example for the prevention of fraud, identification, prevention and management of operational risk, strategic business planning and direct marketing, but only where such direct marketing concerns similar products/services offered to existing clients.

Before processing your data for these purposes, as well as throughout the processing, the agency assesses whether there is a balance between its legitimate interest and your fundamental rights and freedoms or interests. Where your rights and interests prevail, the agency will not undertake or will discontinue the processing unless you have expressly consented to such processing.

Consent

In other cases, for example when offering new products and services that you have not previously used, as well as products and services of our partners, the agency processes your personal data only on the basis of and after obtaining your explicit consent.

6. Third Parties to Whom “PRIMEA PROPERTIES” LTD. Provides Personal Data

“PRIMEA PROPERTIES” LTD. will not provide your personal data to third parties except to the recipients/categories of recipients listed below and where one of the following circumstances applies:

Processing by Another Party on Behalf of the Agency

We provide personal information to affiliated or other trusted parties so that they can process it on our behalf under a contract concluded between us, based on our instructions and in accordance with applicable personal data protection legislation.

These include the following third parties that process your data on behalf of the agency:

  • Partners of the agency under contracts for legal services or document translation services.

  • Providers of systems/services for the management and maintenance of our activities and the quality of our services, including information technology providers with whom the agency has entered into agreements, such as marketing and market research companies, IT and telecommunications service providers, software providers, providers maintaining electronic platforms used by the agency in connection with the provision of services, computer support providers, and others.

“PRIMEA PROPERTIES” LTD. takes the necessary measures to ensure that persons engaged in the processing of personal data strictly comply with personal data protection legislation and the agency's instructions, and that they have implemented appropriate technical and organizational measures to protect personal data.

In Compliance with a Legal Obligation

We share your data with state authorities/institutions, persons exercising public functions, regulators and supervisory authorities, or persons performing public functions, including the National Revenue Agency (NRA), National Social Security Institute (NSSI), State Agency for National Security (SANS), courts, prosecution and investigative authorities, the Commission for Consumer Protection, the Commission for Protection of Competition, the Commission for Personal Data Protection, public and private enforcement officers, and others, as well as with companies, organizations or external parties where we have sufficient grounds to believe that access to, use, preservation or disclosure of the data is necessary for:

  • Compliance with applicable law or another binding legal act.

  • Responding to an inquiry from a state institution or person exercising public functions in connection with or for the purposes of carrying out their statutory functions, an inspection, complaint, audit, etc.

  • Detecting, preventing or taking other action in connection with fraud, money laundering, terrorist financing, technical problems or security-related matters.

  • The exercise of representative functions by your legal representatives or representatives acting under a power of attorney.

  • Taking measures to protect the rights and property of “PRIMEA PROPERTIES” LTD., and ensuring the safety of our clients or the public, as required or permitted by law.

In Performance of a Contract

In order to provide products and/or services requested by you or by a person you represent, or for the performance of a contract to which you or a person you represent is a party, we may provide your personal data to third parties without whose involvement the performance of the contractual obligations would not be possible.

Such parties may include, for example, a lawyer or representative of a real estate agency representing the other party to a preliminary real estate purchase and sale agreement entered into by you, a real estate rental agreement, or a deposit agreement signed by you to reserve a property you have selected from sale; a notary in connection with the signing of the final agreement in the form of a notarial deed; and other persons whose involvement is necessary for the performance of our obligations under the brokerage agreement concluded with you.

With Your Explicit Consent

Outside the cases listed above, we will share your personal data with companies, organizations or external parties where we have your consent to do so.

7. Your Rights as a Data Subject

You have the right:

  • To access the personal data processed by the agency and to request that “PRIMEA PROPERTIES” LTD. correct and update the personal data stored about you. You may do so by submitting a request at the office of “PRIMEA PROPERTIES” LTD.

  • To withdraw, at any time, the consent you have given for the processing and storage of your personal data where the processing is based solely on consent, for example in connection with direct marketing of products/services that you have not previously used, products/services of our partners, or marketing research. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

  • To request the deletion of your personal data stored and processed by the agency where there is no longer a legal basis for processing it.

  • To request restriction of the storage and processing of your personal data by the agency and to object to such processing.

  • To receive the personal data that you have provided to the agency in a structured, commonly used and machine-readable format and to transmit such data to another controller where the data is processed on the basis of your consent or in performance of a contract concluded between you and “PRIMEA PROPERTIES” LTD., and where the processing is carried out by automated means.

  • To lodge a complaint with the Commission for Personal Data Protection at the following address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria, Tel.: +359 2 915 3518, email: kzld@cpdp.bg, and/or another supervisory/regulatory authority if you believe that your personal data has been processed in violation of the applicable requirements.

  • We will respond to your request without undue delay and within 30 days of receiving your request.

  • If we are unable to fully comply with your request within one calendar month due to its complexity, the need for assistance from a third party or the number of requests received, we may extend this period and will explain the reasons for the extension.

8. Retention Period for Your Data

We will retain your personal data for a period not exceeding 6 years, calculated from the year following the year in which the relationship in connection with which your personal data was collected ended, unless another legal basis for processing the data exists.

We retain your data for the following reasons:

  • To be able to fulfil your requests for information.

  • To be able to respond to your questions and complaints.

  • To be able to demonstrate the fulfilment of our obligations towards you.

  • To comply with the agency's legal obligations concerning the retention of client data and documentation relating to completed transactions and operations, as well as documents related to establishing and maintaining commercial or professional relationships.

The storage and processing of your data after the expiry of the above-mentioned period is permitted where deletion is prevented for legal, regulatory or technical reasons, or for reasons related to the implementation of measures to prevent unlawful conduct and cooperation with state authorities/institutions in this regard.

This includes cases involving legal or other disputes related to the relationship between you and the agency, changes in regulatory requirements concerning the retention of a particular type of information, and other objective reasons that require the deletion of data to be delayed.

9. Changes to This Information

We will periodically update this document in order to provide you with the most current and accurate information regarding the processing of your data, in accordance with our policy and applicable personal data protection legislation.

Any changes will be published on the website of “PRIMEA PROPERTIES” LTD. and at the agency's office.